Department of the Treasury Technical Explanation of the Protcol Signed at Washington on January 15, 2013 Amednign the Convention Between the United States of America and the Kingdom of Spain

This is a Technical Explanation of the Protocol signed at Washington on January 14, 2013, the related Memorandum of Understanding signed the same day, and a subsequent Exchange of Notes dated July 23, 2013 (hereinafter the "Protocol", "Memorandum of Understanding" and "Exchange of Notes" respectively), amending the Convention between the United States of America and the Kingdom of Spain for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Madrid on February 22, 1990 (hereinafter the "existing Convention") and the Protocol, which forms an integral part of the existing Convention, signed at Washington on November 6, 2003 (hereinafter the "Protocol of 1990").